A sentencing judge is not required to refer to the totality principle by name; it is sufficient that the judge demonstrates awareness of the total custodial burden when fixing the sentence. Reference to an offender's prior criminal history against the same victim when assessing the gravity of the current offence does not constitute double punishment where the reference explains the effect of the current offence on a vulnerable victim. A non-parole period exceeding 80% of the head sentence, while inviting appellate scrutiny, may be justified where specific deterrence is the dominant sentencing consideration.
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